As the criminal law cannot be used as a tool to harass innocent citizens, the Supreme Court on Friday (October 17, 2025) quashed several FIRs registered in Uttar Pradesh’s Fatehpur district for the alleged crime of “mass religious conversions” of Hindus to Christianity.
In a landmark judgment on appeal The Uttar Pradesh Prohibition of Unlawful Conversion of Religions Act, 2021A bench comprising Justices JB Pardiwala and Manoj Misra quashed as many as five First Information Reports against several persons, including Rajendra Bihari Lal, Vice-Chancellor of Uttar Pradesh’s Sam Higginbottom University of Agriculture, Technology and Sciences (SHUATS).
Justice Pardiwala, who authored the 158-page judgment, found that the FIRs were vitiated by legal infirmities, procedural lapses and lack of credible material and ruled that proceeding with such prosecutions would amount to “a travesty of justice”.
“Blazing Flaws”
“Criminal law cannot be allowed to become a tool to harass innocent persons, allowing law enforcement agencies to initiate prosecutions at will and on the basis of completely unreliable materials…,” the judgment said, citing “glaring defects” in the registration of one of the FIRs filed in 2022.
Referring to the facts of one of the FIRs, the verdict said: “The police had no opportunity to overcome the difficulties by getting vested interests to lodge complaints about the same alleged incident with considerable delay and then launch a new round of investigation against largely the same set of accused persons. Unfortunately, that is the only impression left on us by the material on record.” The Bench rejected the contention that FIRs should not be quashed by the apex court in exercise of its power under Article 32 (right to approach the SC for enforcement of fundamental rights) under the Constitution.
“This court, as the highest constitutional court, has been vested with powers, as enshrined in Part III of the Constitution, to provide remedies against violations of fundamental rights. The very fact that the right to constitutional remedies has itself been enshrined as a fundamental right is a clear confirmation that this court is the ultimate guarantor of their enforcement. Once the Constitution imposes such responsibility on this court, it need not be directly responsible to it.” seek an alternative remedy if the complaint arises out of an alleged violation of a fundamental right,” he said, adding that extraordinary circumstances necessitated the quashing of the FIR.
He went into the facts of each FIR in detail and pointed out glaring lapses including that no conversion victim had approached the police with a complaint.
Also Read: Medieval: On Uttar Pradesh Anti-Conversion Act, Its Amendments
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The Bench, however, ordered the striking out of the pleas relating to one of the six FIRs on the ground that it related to some other offences, for fresh consideration and clarified that the interim protection granted earlier to the accused would continue till the matter is finally decided.
Referring to the judgments, he said: “If the High Court is satisfied that the process of any court is being or may be abused or that the ends of justice would not be secured, it is not only empowered but bound by law to exercise its natural powers…”
However, the Bench said that the UP Act, being a special enactment, prescribes certain special procedural norms unlike the CRPC.
“It is a settled legal position that the intention of the legislature should be interpreted from the plain text of the statute, and if the plain interpretation does not lead to any absurdity or is not impracticable, then the courts should not depart from the meaning that is apparent from the plain text,” he said.
Regarding the veracity of witness statements, he said, “Neither the witnesses underwent illegal religious conversion nor were they present at the scene of the alleged mass conversion on April 14, 2022. Referring to the judgment, the court quashed the FIR saying that “the existence of multiple FIRs for the same alleged incident amounts to abuse of investigative powers”.
The bench said that repeated registration of FIR in connection with the same incident “undermines the fairness of the investigative process and exposes the accused to undue harassment”.
The petitions related to six FIRs filed between December 2021 and January 2023 under various provisions of the IPC and the UP Act.
One of the FIRs was registered on April 15, 2022 at Kotwali Police Station in Fatehpur District on the complaint of one Himansh Dixit, Vice President of Vishwa Hindu Parishad, against 35 named and 20 unknown persons who alleged that 90 Hindus were converted to Christianity in an event on Evangelical India Day before Evangelical Church Day, Maund meaning for Christians.
It was alleged that Hindus were subjected to undue influence, coercion and lured by fraud and promise of easy money.
Proceedings against specific offenses under Sections 307 (attempt to murder), 504 (intentional insult with the aim of causing a breach of the peace) and 386 (extortion) of the MŘ. The accused were also booked under the Anti-Conversion Act.
Published – 17 Oct 2025 23:46 IST
